Written evidence from the Department for Communities (Northern Ireland Executive) (HAB0160)

 

 

 

 

WORK & PENSIONS COMMITTEE HEALTH ASSESSMENTS FOR BENEFITS

 

I am writing in response to your request, on behalf of the Work and Pensions Committee, for evidence about how health assessments for benefits are carried out in the North of Ireland.

 

Since taking up my appointment as Minister for Communities I have made it clear from the outset that my priority is the reversal of social security service privatisation and a return to in-house health assessments that put peoples’ needs, equality and human rights at the heart of the service.

 

Evidence has been gathered for the range of benefits for which my Department has responsibility that incorporate a health assessment to determine eligibility and the rate of benefit payable. This evidence reflects arrangements for health assessments as they currently stand for Personal Independence Payment (PIP), Employment Support Allowance (ESA), Universal Credit (UC) and Industrial Injuries Disablement Benefit (IIDB). It should be noted that for Disability Living Allowance (DLA) and Attendance Allowance (AA), less than 1% of claims received go to the Assessment Provider for an assessment to be completed. The resulting information is attached at Annex 1.As specifically requested, the information provided includes particular learning from the roll-out of PIP in NI, the learning from measures put in place during the pandemic and suggestions for further improvement to benefit application and health assessment processes.

 

I trust that you will find this information useful. Is mise le meas,

 

 

 

 

 

 

 

 

 

 

 

Annex 1

 

 

 

Table of Contents

Background              4

Health Assessments delivery              4

Improvements implemented in NI in respect of health assessment quality              5

Health Assessment Advisory Team              5

Accountability              6

Equality and Human Rights              6

Learning from the implementation of PIP              7

Other PIP Operational Improvements and Initiatives              9

How applying for PIP could be made more straightforward for claimants              10

Use of further evidence              10

Digital GP Factual Report              10

Other Improvements              11

Lessons from the pandemic, including whether changes made to the assessment processes should continue              11

Universal Credit and Employment Support Allowance              13

Special Rules for Terminal Illness              13

Improvements Suggested for UC and ESA              13

Completion of the UC50              13

Medical evidence              14

Access to an online version of the claimant’s completed UC50              14

Access to ESA online claim form              14


Background

  1. In Northern Ireland (NI), the administration of social security benefits is devolved and delivered by the Department for Communities (DfC). While the devolved administration is responsible for benefits policy in NI, DfC adheres, in the main, to the parity principle delivering the same range of benefits, paid at the same rates and subject to the same conditions as in Great Britain (GB).

 

  1. Where NI diverges from parity,

IT must be funded by NI; and

 

  1. The following paragraphs provide evidence on how health-related benefits are assessed and applied in the North for each of the applicable benefits.

 

Health Assessments delivery

  1. Personal Independence Payment (PIP) disability assessments are currently undertaken by Capita for NI, with Work Capability Assessments (WCA) for Employment and Support Allowance (ESA) and Universal Credit (UC) being undertaken by Atos. Atos also deliver assessments for some smaller benefits such as Industrial Injuries Disablement Benefit (IIDB), Disability Living Allowance (DLA) and Attendance Allowance (AA). Less than 1% of DLA and AA claims received go for an assessment. As in GB, existing contracts for Capita and Atos will expire on the 31 July 2023.

 

  1. In parallel with DWP, DfC has established an NI Health Transformation Project to deliver transformation to health assessments and maintain parity with DWP. DfC joined the DWP’s Functional Assessment Service (FAS) procurement as a separate geographical region (Lot 5), for a single provider to deliver the new health assessment service from August 2023.

 

  1. The inclusion of DfC in the FAS procurement and the Department’s policy of maintaining parity will ensure that the same health assessment service is provided in NI within the same timeframe.

 

  1. The Department continues to engage with the Department for Health NI on the potential to bring health assessments in-house on a phased basis.

Improvements implemented in NI in respect of health assessment quality

Health Assessment Advisory Team

  1. Prior to extending the current health assessment contracts until July 2023 in NI, the Department for Communities commissioned an independent review of the health assessment service. One of the recommendations was to in house the clinical auditing of health assessments. In response, the Department expanded its Health Assessment Advisory Team (HAAT) and recruited further Health Professionals to provide clinical assurance for the health and disability benefits contracts. This Departmental team, staffed with HCPs, audit a random sample of the respective Assessment Providers’ assessment reports to ensure that they are of the requisite quality.

 

  1. The objective of in-housing the Independent Audit function was to address any real or perceived conflicts of interest that may have arisen from the contracted Assessment Providers auditing the quality of their own assessments. The in- house function establishes clear independence of the health and disability audit function within overall service provision, improving the governance of contracted suppliers and establishing more robust internal systems of control and assurance.

 

  1. The Department has continued to strive to deliver a positive benefit assessment journey and ensure continuous supplier development and improvement. The HAAT provide valuable clinical assurance via the observation of telephone and face to face assessments and provide insight to identify opportunities for improvement and professional development of both Assessment Provider and Departmental staff. These activities, alongside regular clinical calibration and

senior clinical engagement support the desire for a ‘right first time’ approach and provide quality outcomes for customers.

 

  1. The HAAT have followed a parity position with DWP in relation to customer focus by implementing the Proportional Assessment for Severe Disability – a paper- based report completed on the evidence available on submission of a claim, using clinical expertise and balance of probability with no requirement for review for at least 5 years where the outcome of award is Enhanced/ Enhanced, realising significant benefit for customers.

 

  1. Further to this, the HAAT have also introduced the auditing of initial review decisions which considers appropriate use of and requesting evidence, routing of cases and also ensuring that customers are appropriately safeguarded.

 

Accountability

  1. Commercial Model: Feedback was received that the current contracts focus on profit rather than a customer centred approach. As part of the contract extensions, officials will consider alternative models to incentivise assessment provider’s performance using output related funding to deliver the best value for money with the customer/claimant’s experience at the centre. Targets set will continue to ensure that the quality of the service for the customer is the focus.

Equality and Human Rights

  1. Officials will work with external providers to engage with British Deaf Association and Equality Commission NI so they better understand the assessment process and identify if further support beyond Video Relay Services can be provided to deaf people.

 

  1. Claimant survey reports will be reviewed by the external providers and officials with the intention of including questions in respect of an Equality and Human Rights perspective, and for inclusion at monthly board meetings for further discussion.

  1. External providers will engage with the Advice Sector to provide assurance that processes are in place to ensure Healthcare Professionals have access to training and to specific health champions, such as mental health champions. Engagement will also focus on the disability assessor role, training and qualifications could help address this concern.

 

  1. External providers contact centre staff will receive training from Survivors of Suicide on the subjects of ‘safe talk’ and ‘emotional intelligence’ and further opportunities to enhance their skills in dealing with vulnerable claimants with be sought.

 

  1. A review will be undertaken of information content for all channels, e.g., any correspondence sent to claimants, information pages on both external providers’ and DfC websites, to provide easier to access information, such as car parking options and the reimbursement of travel expenses etc.

 

  1. Officials will regularly review policy and guidance with external providers in relation to the duration of assessment review periods. Continuing audit and monitoring of cases by both the Health Assessment Advisory Team and operational case managers will ensure award lengths are appropriate and in line with guidance. Feedback will be provided to the external provider and relevant Healthcare Professional where there is a learning need identified.

 

Learning from the implementation of PIP

  1. In NI, due to a delay in the passage of the Welfare Reform Legislation, PIP was not implemented until June 2016. DWP had introduced PIP through a phased introduction starting in April 2013. For a variety of reasons, backlogs emerged nationally. In 2014 the National Audit Office examined DWP’s progress in implementing PIP and the reasons why backlogs had developed.

  1. The delay in introducing PIP in Northern Ireland provided DfC with the opportunity to learn from DWP and its Assessment Providers experiences. Through extensive engagement on lessons learnt with DWP, and Capita, the Department was able to recruit and train enough Health Professionals (HCP) and successfully implement PIP without similar experiences of backlogs in GB. The availability of adequate numbers of appropriately skilled and trained HCPs continues to be key to timely delivery of health assessment. In conjunction with DfC,

 

  1. The importance of proactive stakeholder engagement was recognised as a crucial part of PIP implementation. Capita and the Department attended a series of engagement events with advice groups and disability organisations ahead of PIP go-live, 17 in total, to explain the end-to-end customer journey for PIP and address any concerns raised. Since PIP go-live in 2016 Capita continues to attend quarterly meetings of the Disability Consultative Forum to address any operational service issues raised.

 

  1. During the reassessment of approximately 128,000 Disability Living Allowance (DLA) claimants for PIP, as an additional safeguard the Department introduced an additional step in the process that had not been adopted by DWP. Usually, a claimant would receive an automatic PIP disallowance if they failed to return the PIP2 application form. The Department decided not to automatically disallow claimants who didn’t return their form but instead arranged for an Outreach officer to contact the claimant to establish why they had not returned their form and to establish whether further support was required.

 

  1. The Department also decided that all claimants transitioning from DLA to PIP would be asked if they wanted the evidence from their DLA claim to be used as evidence on their PIP claim. This evidence would then be automatically uploaded to the PIP claim.

Other PIP Operational Improvements and Initiatives

  1. Aligned with the approach in DWP, several improvements to the assessment process have already been introduced including the completion of PIP award reviews in-house where sufficient evidence is available. This has reduced referrals to the PIP Assessment Provider by 25%.

 

  1. The Department will continue to focus on expanding the in-housing of PIP decisions. Where assessments are required, officials are working closely with the PIP Assessment Provider to maximise the appropriate use of paper-based reviews, which will reduce the need for a claimant to attend an assessment.

 

  1. Future planned improvements to the PIP process include:

 

      Digital pathway for receipt of a GP short summary report

      Enhanced role for the Departments outreach service where accessibility issues present and a full benefit check for those claiming PIP who are terminally ill

      Increase Paper Based Reviews – strengthening the Providers’ triage process to identify where reviews could be completed without the requirement for a full assessment

   Greater choice of assessment type - greater choice for customers through a blend of assessment methods.

      Customer insight and evaluation of assessment channels used to inform the future delivery model.

      Timing of Surveys – Customer surveys will be conducted before and after an assessment decision. This will provide a more accurate gauge of satisfaction levels, not skewed by any outcome.

      Recruitment and Retention of Assessors – work with Providers in relation to demand forecasting and capacity planning to maximise assurance that there are sufficient healthcare professionals available to meet demand.


      Further Medical Evidence - the Department will work with external providers to promote early use of further evidence. Discussion ongoing with the Department of Health NI regarding facilitating the sharing of medical evidence.

      Progression of outstanding recommendations from Rader and Cavanagh independent reviews of PIP.

 

How applying for PIP could be made more straightforward for claimants

  1. DfC is currently working alongside DWP on a digital solution for PIP applications known as PIP Apply. This will result in full digitalisation of the PIP application process, whilst retaining the existing methods to apply for PIP, including by telephone.

Use of further evidence

  1. The Northern Ireland Public Services Ombudsman has conducted an “Own Initiative” review of PIP in Northern Ireland. The report contained 33 recommendations. The theme of the report was the importance of getting further medical evidence at the outset of the claim to support robust decision making, to reduce the number of assessments required, and to reduce disputes. The Department is working, where possible, to address and implement these recommendations, subject to affordability and feasibility. A number of system changes within the recommendations have been accepted by DWP and will be implemented nationally.

Digital GP Factual Report

  1. The Department and Capita are currently working on a proof of concept for an electronic GP Factual Report (eGPFR) as an alternative to the existing form which needs to be completed clerically. Three GP practices have agreed to participate in this proof of concept which will provide feedback. Full roll out of this service is intended to make it easier for GPs to complete and return further medical evidence.

 

  1. In the longer term the Department is aiming to obtain medical evidence directly from GP practices and health trusts. In NI the IT within Health Trusts and GP

practices is currently fragmented. The Department of Health (DoH) is currently developing a single IT system to provide to the Trusts which will ensure easier access to medical evidence. This is expected to be rolled out in Northern Ireland in all Health Trusts by 2028 with GP practices to follow at a later date. DfC are engaging with DoH to gain access to this system subject to claimant consent and GDPR. This will be instrumental in improving the health assessment service as it may reduce the need for a claimant to be called for an assessment.

 

  1. From 2025, the DfC will gradually rollout the DWP Health Assessment Service (HAS) IT system which will streamline and improve the sharing of medical evidence across benefits.

 

Other Improvements

  1. The Department is exploring the option of introducing a ‘Voice of the Claimant’ forum which will enable claimants to share their experiences of their assessment journey. This will highlight areas for improvement as well as areas that are carried out well which will ultimately improve the assessment due to lessons learned. In the meantime, regular stakeholder engagement with local customer representative groups is a source of feedback on the application and health assessment customer journeys.

 

  1. The Department have rolled out a digital audio recording solution in the PIP contract, subject to the customer’s consent. The aim of this is to reduce the number of complaints and disputes lodged. This will be rolled out across all benefits in August 2023 when the FAS contract is implemented.

 

Lessons from the pandemic, including whether changes made to the assessment processes should continue

  1. Prior to the COVID-19 pandemic, assessments in Northern Ireland were conducted by either paper-based assessment or, where this was not possible, by face-to-face (F2F) assessment. Due to the impact of Covid-19, DfC moved to telephony assessment.

 

  1. To support this and assure the Department of the robustness of these assessments, telephone observations were set up in conjunction with the Department’s Health Assessment Advisory Team, the outcomes of which spoke to the success of this process. Quality Audit scores remained largely in line with what they had been in the pre-pandemic environment.

 

  1. The Department carried out a customer survey which indicated that claimants preferred to have a range of assessment options and as a result the Department will adopt a multi-channel approach (i.e., telephony, face-to-face and paper-based review as appropriate) going forward.

 

  1. The success of health assessment channel change has allowed the Department to take steps towards the reintroduction of face to face assessments in a controlled manner, moving towards a target of 20% of assessments being completed in a face to face environment. Face to face services will be extended to claimants who prefer this method or to those who would benefit most from it. All channels will be subject to quality assurance to ensure that they are fit for purpose.

 

  1. For Industrial Injuries Disablement Benefit face to face assessments are required in order to determine if there has been loss of faculty and if so, to what degree, to enable the Department to award the appropriate rate of benefit. During the pandemic these could not be completed and this led to a backlog of claims within IIDB. As part of the recovery plan for face to face services, other Health Care Professionals including physiotherapists, were trained to complete IIDB assessments in addition to Doctors. This gives greater flexibility and is in place moving forward.

 

  1. The completion of forms, such as the PIP2, UC50 or ESA 50, can prove difficult for a lay person to articulate the difficulties and impact of their health condition and many will seek assistance with completion from the Advice Sector NI. While the timescales for returning such forms are 4 weeks, or such other time as the

Department considers reasonable, the Department allowed an additional 4 weeks to return if required and this easement is still in place.

Universal Credit and Employment Support Allowance

  1. Both ESA and UC in the North remain focused on improving the health journey of claimants to ensure delivery of the high-quality service claimants rightly expect and deserve. Officials work extensively and closely with external stakeholders to ensure their insights and experiences are captured and improvements to process and external online communications are put in place. This engagement has helped identify several customer service improvements.

 

Special Rules for Terminal Illness

  1. If a medical professional has advised that the claimant has 12 months or less to live, a WCA referral is not made, a claimant commitment is not completed and the customer is automatically placed within the Support Group for ESA or LCWRA group for UC. Recent changes to the Special Rules claimants nearing the end of life were introduced in April 2022 in the North and saw a change from 6 months to 12 months for all 5 benefits (ESA, UC, PIP, DLA and AA), whereas in GB the changes were only applied to ESA and UC.

 

Improvements Suggested for UC and ESA Completion of the UC50

  1. A more simplified, online user friendly UC50 questionnaire would help improve

customer experience with using the form and the overall quality of the information provided in advance of a WCA. An online UC50 questionnaire that includes prompts and explanatory notes as the claimant navigates their way through the form and one that has been tested by claimants in Northern Ireland. We understand an online UC50 questionnaire is currently being tested in DWP, its content and the user functionality built into the form are not known at this stage. Whilst DWP are progressing work on a digital UC50, there appears to be no plans currently to progress a digital ESA50 however, if work is undertaken by DWP to progress this, DfC will ensure inclusion in this work to maintain parity for our customers.


 

Medical evidence

  1. The supply of further medical evidence with a completed ESA50 or UC50 questionnaire can be beneficial for a customer therefore increasing awareness of its importance and influence on the WCA outcome could be further promoted on the questionnaire.

 

  1. Within ESA, if the claimant does not have the required points and the ESA decision maker is considering a disallowance, they will telephone the claimant first to establish if they have any further evidence they wish to submit for consideration. This is another positive process for the claimant to ensure that all reasonable steps have been taken prior to a disallowance decision being made.

 

Access to an online version of the claimant’s completed UC50

  1. Access to a copy of the claimant’s completed UC50 questionnaire would be beneficial to claimant for the purposes of mandatory reconsiders and appeals and having someone advocate on their behalf.

 

Access to ESA online claim form

  1. During the pandemic and given the need to provide a responsive service, the Department implemented an on-line claim form, using the Citizen Space platform, which allowed customers to complete their application at a time of their choosing whilst also continuing to provide a telephony service where customers can make their application over the telephone. This provided greater flexibility for customers and led to an improved service.

 

  1. Whilst DWP have introduced an on-line claim form, DfC was not considered in scope of the implementation of this digital system. DfC has been working with DWP to understand the timescales involved with implementing the DWP on-line service to maintain parity for DfC customers.

 

  1. In addition to the on-line application form, further digital developments are being progressed for ESA customers. The most recent was the DWP initiative where

customers can request a copy of their “proof of benefit” on-line thereby giving them quicker access to their own information and negating the need for a telephone call to the department.

 

July 2022